Authored By: Wuraola Alamutu
Obafemi Awolowo University, Ile-fe.
ABSTRACT
This article examines labour and employment law in sports, focusing on the Nigerian context and global comparisons. It explores the enforcement of footballers’ rights, regulation of contracts, and the tension between sports autonomy and legal oversight. Drawing on Nigerian cases such as Osiwa Igbuya v Delta State Football Association and Deputy Echeta v Rivers United FC & NFF, as well as international disputes before the Court of Arbitration for Sport (CAS), the paper highlights challenges of weak enforcement, ambiguous contracts, and overlapping jurisdictions. It concludes by advocating reforms in dispute resolution, unionisation, and supervised autonomy to strengthen sports governance in Nigeria and align with global best practices.
INTRODUCTION
Sport is no longer confined to leisure or competition; it has developed into a global industry governed by intricate legal frameworks. Labour and employment law occupy a critical place within this structure, regulating contracts, rights, duties, and dispute resolution between athletes, clubs, and federations. Employment law focuses on individual relations between employer and employee, while labour law encompasses collective concerns such as trade unions, strikes, and collective bargaining. Both apply squarely to sports, where contracts, welfare, and discipline are often contested.
Globally, athletes are recognised as employees with enforceable rights. Roger Welch notes that professional athletes, coaches, and staff are subject to ordinary labour rules, raising issues of termination, freedom of movement, discrimination, and fair treatment. By contrast, Nigeria’s sports law framework remains underdeveloped. While statutes such as the National Sports Commission Act and Nigeria Football Association Act exist, enforcement is weak, institutional support is poor, and gaps persist between federation rules and national law.
This article focuses on three interrelated themes:
- enforcement of footballers’ rights in Nigeria
- regulation of contracts in Nigerian sports law
(iii) balancing sports autonomy with legal oversight. Through comparative analysis, it seeks to highlight how Nigerian sports law can evolve in line with global best practices.
ENFORCEMENT OF FOOTBALLER’S RIGHTS: Redress for Labour Disputes in Nigeria
One of the most pressing concerns in Nigerian sports is the ability of athletes to enforce their rights. Disputes over unpaid wages, unfair dismissal, and poor welfare are common, yet players often lack avenues for redress. Weak enforcement of labour laws, opaque club practices, and inadequate welfare systems render many footballers vulnerable.
The National Industrial Court (NIC) provides a statutory forum for redress. In Osiwa Igbuya v Delta State Football Association & Anor (NIC/EN/01/2008), a footballer successfully challenged his association over unpaid entitlements, demonstrating that athletes can, in principle, assert labour rights through the NIC.[1] However, such cases remain rare due to the high cost of litigation, lack of awareness, and weak institutional support.
At the international level, CAS offers a specialised forum for disputes arising under FIFA regulations. Yet Nigerian players rarely benefit from CAS procedures, which are expensive and procedurally complex. By contrast, in the United Kingdom, the Professional Footballers’ Association (PFA) actively represents players, ensuring that contractual breaches are addressed promptly. This model demonstrates the importance of effective unions in professionalising sports employment relations.
For Nigeria, stronger domestic dispute resolution mechanisms are needed. Empowering the NIC, promoting arbitration within football federations, and strengthening unions would provide athletes with reliable remedies. Ultimately, protecting footballers’ rights enhances not only fairness but also the credibility and commercial viability of Nigerian sport.
REGULATION OF CONTRACTS IN NIGERIA SPORTS LAW
Sports contracts in Nigeria are governed by a combination of constitutional, statutory, and regulatory instruments. The Constitution of the Federal Republic of Nigeria 1999 provides the overarching legal framework, while specific statutes such as the National Sports Commission Act, the Nigeria Football Association Act, and the National Institute for Sport Act supplement regulation. Additionally, federations like the Nigeria Football Federation (NFF) regulate contractual standards.[2]
A sports contract typically includes provisions on duration, salary, bonuses, performance obligations, termination, confidentiality, and disciplinary matters. Unlike ordinary employment contracts, they often include clauses on image rights, sponsorship, intellectual property, transfers, and anti-doping. To be valid, contracts must satisfy general principles of Nigerian contract law: competent parties, offer, acceptance, consideration, and lawful purpose.[3]
Despite these frameworks, challenges abound such as;
Ambiguity: many contracts lack clarity on termination, injury compensation, or intellectual property, leading to disputes.
Regulatory overlap: NFF rules sometimes conflict with FIFA or CAS regulations, raising questions of jurisdiction.
Government interference: sponsorships or licensing deals are occasionally voided for non-compliance with policy. A notable example is the termination of the PUMA–Athletics Federation of Nigeria sponsorship agreement, worth USD 2.7 million, due to governance disputes.[4]
The recent case of Deputy Echeta v Rivers United FC & NFF (CAS 2025/A/11424) illustrates these issues. Echeta challenged contract breaches including unpaid wages and unlawful suspension before the NFF Players Status & Arbitration Committee (PSAC). When PSAC reversed its own ruling, Echeta escalated to CAS.[5] The dispute highlights the need for transparent arbitration, enforceable judgments, and stronger contractual safeguards.
Reform is essential. Nigerian sports contracts should include clear dispute resolution clauses specifying NIC, PSAC, or CAS jurisdiction. Athletes require legal advice before signing contracts, especially regarding image rights and termination clauses. Furthermore, government interference should be minimised to avoid arbitrary revocation of legitimate agreements.
BALANCING SPORTS AUTONOMY AND LEGAL OVERSIGHTS
A central debate in sports law concerns the balance between self-regulation by sports federations and state oversight. Sports bodies claim autonomy to regulate under their own rules, while governments emphasise that no organisation should be above the law. Begović notes that sports operate within a dual system: private regulation through federations and public oversight through labour law.[6]
Sports autonomy may be legal, political, financial, or pyramidal. For example, FIFA exercises pyramidal autonomy by regulating federations worldwide, while national bodies like the NFF claim legal autonomy in drafting rules. Autonomy fosters uniformity and independence but can also be abused where internal rules conflict with labour protections.
Comparative experiences show different approaches. In Montenegro, for instance, sports federations retain autonomy but their rules must comply with labour legislation and constitutional protections.[7] Similarly, European courts have reinforced that autonomy cannot override labour rights. In the European Handball Court of Arbitration (2024), an athlete prevailed in a claim for unpaid wages during pregnancy, affirming that basic employment rights must prevail over sports rules.[8]
Nigeria faces similar tensions. Federations often adopt rules that undermine employment rights, such as restrictions on contract duration or access to social security. The NIC plays a vital role in ensuring that federations remain subject to the rule of law. A balanced model is that of “supervised autonomy”, where sports bodies retain independence but remain subject to constitutional safeguards. This approach respects the specificity of sport while preventing abuse.
CONCLUSION
Labour and employment law in sports require a delicate balance between autonomy and legal oversight. In Nigeria, weak enforcement, ambiguous contracts, and overlapping jurisdictions leave athletes vulnerable. Cases such as Osiwa Igbuya and Echeta v Rivers United FC & NFF illustrate both the potential and shortcomings of existing mechanisms. By strengthening dispute resolution, professionalising contracts, and promoting supervised autonomy, Nigerian sports can align with global standards, ensuring fairness, accountability, and athlete protection.
Reference(S):
[1] Osiwa Igbuya v Delta State Football Association & Anor NIC/EN/01/2008
[2] Constitution of the Federal Republic of Nigeria 1999(as amended); National Sports Commission Act; Nigeria Football Association Act; National Institute for Sports Act.
[3] ‘Sports Law in Nigeria: Contracts, Sponsorships and Athlete Rights’ (Mondaq,12 October 2023).
[4] ‘PUMA Terminates its Four-year Contract with Gusau’s AFN’ (Premium Times, 5 August 2021).
[5] Deputy Echeta v Rivers United FC & NFF CAS 2025/A/11424
[6] Marko Begovic, ‘Specifity of Employment Relations in Sports: Lessons from the National Context’ (2025) 23(1) Entertainment and Sports Law Journal 1.
[7] Parliament of Montenegro, Law on Sports (Official Gazette No 44/2018; 123/2021)
[8] European Handball Court of Arbitration, Case No 20808 (2024)





